Employees and directors (whether or not citizens of the United
States) are prohibited from trading in Corporation stock (the buying or selling of Corporation securities), based on material, non-public information. Information is material if it has the potential to affect the price of the
Corporations stock. It is non-public if the information has not been released to

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the public at large by means of a filing with the SEC or a press release issued through a major wire service.
Furthermore, such information cannot be given to a third party for the purpose of trading in Corporation securities (a practice generally referred to as tipping). Additionally, employees and directors (whether or not citizens of the
United States) who may have obtained material, non-public information regarding other companies (such as our customers, vendors or competitors) in the course of their employment are prohibited from trading in the securities of such companies.